Looking ahead to a busy year for retirement plans

Although the first quarter of 2026 has continued to be slow for retirement plan legislation and regulatory guidance, employers will be busy with retirement plan-related issues for the remainder of the year. Read on for our review of a few significant issues — and in some cases reminders — that employers will face this year.

Mandatory Roth catch-up reminder

Last year, we shared a couple of articles that touched on the mandatory Roth catch-up contribution rules that became effective on January 1 of this year. These new rules require that any catch-up contributions made by highly paid participants (“HPP”) in 2026 must be made on a Roth basis. A participant is considered an HPP in 2026 if they had more than $150,000 in FICA wages in 2025 from the employer sponsoring the plan. This means any catch-up contributions made by the HPP in 2026 must be made on a Roth basis.

Employers should have already reached out to their HPPs, informing them of the new rules. If you have questions about how to implement the new rules, please contact your Relationship Manager.

Cycle 2 403(b) Restatement

As a reminder, employers using Union Bank’s preapproved 403(b) document must adopt a restated Cycle 2 document no later than December 31, 2026. We expect to deliver a restated Cycle 2 restatement document to 403(b) clients before June 1, 2026.

SECURE Act of 2019 and SECURE 2.0 Act amendments

This year, all of our retirement plan clients — 401(k) and 403(b) plan sponsors alike — that use a preapproved Union Bank plan document must amend their plans to comply with the SECURE Act of 2019 and the SECURE 2.0 Act. The deadline for non-governmental employers to adopt the SECURE/SECURE 2.0 amendment is December 31, 2026. The deadline for governmental employers (e.g., 403(b) plans sponsored by public schools) is December 31, 2029.

The RPS team expects to deliver this amendment to its preapproved plan clients — including governmental employer-clients — in the third quarter of 2026.

Paper benefit statements

While the trend has been for more 401(k) plan participants to receive their quarterly benefit statements electronically, beginning in 2026, SECURE 2.0 generally requires participants, including participants who receive their statements electronically, to receive at least one paper quarterly benefit statement per year.

Our team is reviewing the Department of Labor’s proposed regulations issued in March 2026 and will provide additional information to our affected clients in the near future.

Trump accounts

Finally, while not a retirement plan issue, the Department of Treasury has issued guidance regarding Trump accounts that may be established under the One Big Beautiful Bill Act (“OBBBA”), which was passed into law in 2025.

A Trump account is a traditional IRA established for the benefit of eligible children. Among other topics, the Treasury guidance issued in December 2025 (as well as proposed regulations released in March 2026) addresses how Trump accounts are established, as well as the contribution, distribution, investment, and taxation rules that apply to Trump accounts.

Relevant here, Trump accounts may be established by an employer as an employee benefit under Internal Revenue Code Section 128. For example, an employer can make an annual contribution of $2,500 (to be adjusted for inflation) to a Section 128 Trump account for an eligible employee or the employee’s beneficiary. The employer contributions will not be taxed to the employee.

Alternatively, if offered by an employer, an employee can make pre-tax salary reduction contributions to a Section 128 Trump account through an employer’s Code Section 125 cafeteria plan. However, in this case, the Trump account must be for the employee’s beneficiary and cannot be for the employee.

Although the March 2026 proposed regulations did not address Section 128 Trump accounts, the employee benefits community is hopeful that the Treasury Department will issue additional guidance — including the plan document requirements — ahead of the July 4, 2026, date when contributions can first be made to Trump accounts.

As always, should you have any questions about the topics we covered here, please do not hesitate to contact your RPS Relationship Manager and we’ll be happy to help.